Attorneys & Solicitors

1629 K Street NW Suite 300

Washington DC 20006 USA
Tel/Fax 1-202-318-2406
chambers@brimstoneandcompany.com
www.brimstoneandcompany.com

March 19, 2014

Cardinal Prefect George Pell

Secretariat for the Economy
00120 Vatican City State

Appeal to the The Secretariat for the Economy in re The Ustasha Treasury

Dear Cardinal Pell:

Congratulations on your appointment to head the Secretariat for the Economy in

order to carry out the ongoing reform efforts of the Holy Father

On January 20, 2014, I sent the attached letter detailing the involvement of the
Vatican Bank (IOR) with the Ustasha Treasury and the need to definitively
address this matter in conjunction with the ongoing efforts to reform the IOR.

Unfortunately no response has been forthcoming yet but that does not dampen
our enthusiasm in resolving this longstanding case for our clients. One problem
in the past is there has been no centralized authority empowered to handle cases
like the Ustasha Treasury. The Papal Motu Proprio that established the
Secretariat for the Economy now vests the requisite authority in Your Eminence.

I omitted to mention in my earlier letter that there truly is no doubt the major war
criminal Ante Pavelic was harbored at the Vatican 1945-1947. I direct your
attention to the attached document from the US National Archives which was
belatedly provided to me 12 years after I requested it and too late to be used in
US court proceedings against the IOR and the Franciscan Order OFM.

I pray that finally we may obtain long overdue closure in this matter through
your intercession and guidance. To facilitate a successful outcome I suggest a
meeting be arranged at the Vatican early in the week of June 23, 2014.

Page | 1
Sincerely Yours,

Dr. Jonathan Levy

Legal Representative for Ustasha Treasury Claimants

ATTACHMENTS

Page | 2
 Attorneys & Solicitors
1629 K Street NW Suite 300
Washington DC 20006 USA
Tel/Fax 1-202-318-2406
chambers@brimstoneandcompany.com
www.brimstoneandcompany.com

January 20, 2014

His Holiness, Pope Francis

Apostolic Palace
00120 Vatican City State

Re: IOR Accounts and the Matter of the Ustasha Treasury

Your Holiness:

We are encouraged by the recent openness of the Vatican regarding the affairs of
the IOR - Istituto per le Opere di Religione. However, there can be no true
reconciliation of accounts without first addressing the historic case of the
Ustasha Treasury.

I represent several organizations and individuals in Europe and North America

who are either Second World War survivors or descendents of victims or whose
membership includes either survivors or descendents of Second World War
victims and have an organizational interest in the Ustasha Treasury or legal
claim thereto. Among the organizations I represent are the Jasenovac Research
Institute, Republik Srpska Krajina in Exile, Jasenovac Memorial Centre of
Belgrade, and the Independent Council of Serbian Roma.

The Ustasha Treasury refers to particular events in 1946 involving the transfer of
funds and assets of the defunct Independent State of Croatia (1941-1945) to
various proxy accounts at the IOR.

Over the past few years we have unsuccessfully tried to make contact with
Cardinal Nicora and Mr. Bruelhart at the AIF as well as Mr. Lena who I know
quite well from the lawsuit Alperin v. Vatican Bank, Alfred Moses at
Promontory Group and Mr. von Freyburg at the IOR to no avail on a very long
standing dispute we would like to resolve. Mr. Bruelhart and Mr. Moses did

Page | 1
acknowledge receipt of my correspondence but nothing has come of it. I am
now writing to you in hopes of avoiding yet more litigation and frustration.

We are not requesting any specific remedy at this time; only that the IOR come
to the realization that they must begin to deal with this matter in good faith. The
individuals responsible for the acts committed in connection with the Ustasha
Treasury by and large are deceased and their legacies well established. It is not
our intention to vilify or tarnish reputations but to obtain closure for our clients
and in that way bring about understanding and reconciliation to former
Yugoslavia and peace to the victims and their families.

At this point before we list the rather long winded details of the matter I want to
express my hope that Your Holiness may take a personal interest in this matter.
As in all disputes, there are extreme views on both sides. However, surely the
issue of Second World War assets that were held at the IOR through accounts
can finally be discussed 70 years later without acrimony? I have been working
on this case since 1998 and have never lost my sense someday closure would be
possible.

This is an offer to compromise our dispute with the IOR about the Ustasha
Treasury and related allegations of money laundering. We have repeatedly
requested the IOR and AIF begin to process our complaint about not only the
historic but potentially ongoing money laundering of the Second World War era
assets commonly known as the “Ustasha Treasury” which consists of looted
assets taken in violation of international and domestic laws. This request
includes the retained remainders and the profits and unjust enrichment derived
from the Ustasha Treasury by certain account holders at the IOR.

“Looted Assets” is defined as, but not limited to, any and all personal,
commercial, real, and/or intangible property, including cash, securities, silver,
gold, jewelry, businesses assets, art masterpieces, equipment, collectibles,
religious items, livestock, communal and intellectual property, that was illegally
and/or improperly taken from the ownership or control of an individual,
organization or entity, by means including, but not limited to, theft, forced
transfer, ransom and exploitation, during the period of April 1941 through May
1945 by any person, organization or entity acting on behalf of, or in furtherance
of the acts of, the Ustasha Regime, its officials, agents or related entities, in
connection with crimes against humanity, war crimes, crimes against peace,
genocide, or any other violations of fundamental human rights.

The Ministry of Colonization of the Ustasha Regime carried out much of the
institutional looting. The Ministry’s mission was to ethnically cleanse regions of

Page | 2
Serbs and Roma, liquidate their belongings for the benefit of the Ustasha
Treasury and redistribute land to Croats, Muslims, and Volksdeutch. For
example in the regions of Kozara and Prosara, in 1942 alone, grain and cattle
worth over 100 million Kuna were confiscated from Serbs who had either fled in
well founded fear of their lives, been summarily executed, or were sent to
concentration camps. This was repeated nationwide as Serb regions were
plundered; livestock were driven to central locations like the fairgrounds at the
Croatian town of Hrvatska Dubica and sold, the funds being deposited in the
Ustasha treasury. Jews were treated similarly, for example in the town of Bihac
in 1941, Jews were rounded up, their belongings expropriated by agents of
Ustasha Regime and transported to Ustasha Treasury in Zagreb by rail.

The property of Jews was meticulously documented and disposed of by branches

of the Ustasha State Treasury Department for the benefit of the Ustasha Regime
and addition to the Ustasha Treasury. The Croatian State Archives currently
contains specific documentation of this stolen property including 20,000
dossiers, one for each Jewish family, including property declarations listing both
moveable and immovable assets.

Of particular interest to the Ustasha Regime were items of gold. A ransom of

1004 kilos of gold items was collected from the Jewish community of Zagreb
alone by the Ustasha Regime in 1941. The Jewish Community of Zagreb
eventually was dispossessed of 82 bags of gold items, 19 boxes of jewelry and
diamonds, four boxes of pearl necklaces, six bags of gold coins, 1 bag of cast
gold, and various foreign currency. This extortion from Jews was repeated
throughout Croatia by the agents of the Ustasha Regime until the Jews were
eventually murdered. Only 20% of the prewar Jewish population survived the
Ustasha persecutions either by being named honorary Aryans by Pavelic or
through the intervention of Italian military units stationed within the Ustasha
Regime’s territory or nearby.

Organized robbing of Roma (Gypsies) began in as early as April 1941 and was
in full swing by 1942. The agents of the Ustasha Regime in 1942 alone
confiscated 200,000 gold coins, millions of banknotes, and various jewelry and
clothing from the Roma. The Independent Council of Gypsies in Serbia has
collected over one thousand claims from its members regarding Ustasha looting.
Typical items looted included: gold crucifixes, rings and icons, gold and silver
ducats (the ducat was the trade coin of central and eastern Europe), and
livestock. The valuable items taken from Roma were shipped directly to the
Ustasha Regime’s repositories in Zagreb and the other items sold and then
transferred as cash to Zagreb and the Ustasha Treasury. The Ustasha Regime
maintained a strict policy towards diversion of looted property for personal use.

Page | 3
Some Ustasha officers arrested by the Interior Ministry for diverting Gypsy gold
for their own profit at Jasenovac concentration camp were tortured and then
executed as an example to others who might be tempted to divert looted property
to their own account.

Between 1941 and 1945 the Ustasha Regime plundered the contents of over 300
Orthodox Churches and monasteries in Croatia, Bosnia, Krajina, and Serbia.
Special Ustasha units transported dozens of railway car loads full of icons,
valuable books, manuscripts, church vessels, and gold and silver items to Zagreb
pursuant to Ustasha Regime Order LXXXVII 135 - Z.p. 1941 to remove from all
Orthodox churches before their destruction, all moveables including icons and
iconostasis. The value of these properties has been estimated by the Holy Synod
of the Serbian Orthodox Church to have been tens of millions of dollars.

The term “Ustasha” refers to a Croatian fascist organization placed in charge of

the Independent State of Croatia by agreement of the Axis Powers in April 1941
and which ruled through May 1945, after which time its leaders fled into exile in
Austria and Italy before being moved via the so called Ustasha or Vatican
“ratline “to Spain, Lebanon, the United States, Europe, Australia and Latin
America.

The “Ustasha Regime” is defined as the fascist government of Croatia from

April 1941 through May 1945. Its agents included the Ustasha party members,
police, armed forces, diplomats and government ministries.
The “Ustasha Ratline” refers to a network consisting of Ustasha Regime, OFM
(Order of Franciscans Minor) and other Roman Catholic priests utilizing the
offices of the Croatian Confraternity of Saint Jerome in Rome and funds from
the Ustasha Treasury to facilitate and arrange the escape of over two hundred
wanted Ustasha war criminal to Argentina and elsewhere 1945-1949. The
agents involved in managing this network were Fr. Dominik Mandic OFM who
worked with Fr. Draganovic, Pavelic’s son-in-law Vilko Pecnikar, and
Monsignor Juraj Madjerec, the Rector of the Pontifical College of San Girolamo.

Mandic, Draganovic, and OFM quickly established a plan of action - Ustasha

fugitives would be sheltered by Mandic and Draganovic through the Croatian
Confraternity of San Girolamo or St. Jerome (henceforth Croatian Confraternity)
in Rome. The Croatian Confraternity of St. Jerome (San Girolamo) was
reestablished in 1945 by Mandic and Draganovic as a separate juridical entity at
the premises of The Pontifical Croatian College of St. Jerome in Rome. The
original Croatian Confraternity had been disbanded in 1901. Funds from the
Ustasha Treasury were used as part of the operation as well as being converted
and banked on behalf of the fugitive Ustasha war criminals. At no time, was

Page | 4
Mandic, a senior official of OFM acting on his own behalf. OFM and its Vicar
General and his successors made an informed decision to become involved with
the remnants of the Ustasha Regime despite foreknowledge of their genocide of
Holocaust victims. Sometime after OFM Minister General Bello’s unexpected
death in July 1944, a new Minister General, the American priest, Rev. Valentine
Schaaf, was eventually appointed by the Pope in 1945 as Minister General of
OFM with Mandic continuing as a General Definator. Upon Schaaf’s death in
1946, Mandic continued as a Definitor General and OFM Treasurer through
1951. Further Mandic was under an oath of obedience to OFM and its Minister
Generals and did not act on his own behalf thus the re-creation of the
Confraternity of St. Jerome was therefore specifically condoned by OFM and
Mandic’s association with Draganovic condoned by OFM

The “Ustasha Treasury” refers to a horde of “looted assets” originally

plundered from Serbs, Jews, and Gypsies in Croatia, Bosnia-Herzegovina,
Dalmatia, portions of Slovenia and Serbia, and from citizens of the former
Soviet Union by agents of the Ustasha Regime and revealed as having been
concealed since May 1945. These assets have been named collectively the
“Ustasha Treasury” by the United States State Department in the 1998
Eizenstat/Slany Report entitled U.S. Concerns About the Fate of the Wartime
Ustasha Treasury.

Upon the imminent fall of the Ustasha Regime in May 1945, OFM and its Vicar
General Policarp Schmuel (Acting in place of the Minister General Bello who
had died in 1944) detailed to its General Definitor, Dominik Mandic, the urgent
task of providing aid to Croatians fleeing Tito’s Communists, including those
members of the Ustasha Regime who had successfully fled Zagreb to Austria
and Italy. To carry out his instruction from OFM, Mandic entered into a
partnership with a Vatican official, Fr. Krunoslav Draganovic, who was a
Croatian priest and who was also a former official of the Ustasha Regime’s
Colonization Ministry and member of the Ustasha Party. The Colonization
Ministry was responsible for looting property from Serbs in Slavonia, Srem, and
Krajina. Draganovic also held the rank of Lt. Colonel in the Ustasha Regime
Armed Forces and had served at Jasenovac Concentration Camp. Draganovic
was not only aware of the Ustasha Regime’s atrocities against Holocaust victims
but had witnessed them first hand and had engaged in and had helped coordinate
the organized looting of Holocaust victims’ property. In 1943 Draganovic as a
priest and an expert in looted property was detailed as a Croatian diplomat to
Rome by the Ustasha Regime and was recalled to Zagreb by Pavelic before the
fall of the Ustasha Regime to remove an unknown quantity of the Ustasha
Treasury to the Vatican before the end of Second World War. With the
imminent fall of the Ustasha Regime in the final years of the war, Draganovic
was appointed by the Vatican Pontifical Commission of Assistance as Apostolic

Page | 5
Visitator to the Croatians reporting to Vatican Under Secretary of State Montini
(later Pope Paul VI), a position that provided Draganovic travel documents in
post war Europe as a Vatican emissary. Draganovic’s association with the
Ustrasha regime was known to both Montini and Mandic.

In the closing months of the Second World War, this plunder was collected from
various repositories and banks in Zagreb by the Ustasha Regime dictator Pavelic,
who personally supervised its partial evacuation in several tranches from Zagreb
to Switzerland. In late 1944 or early 1945, Fr. Krunoslav Draganovic transported
an unknown quantity of the Ustasha Treasury to Rome and the Vatican at the
behest of Pavelic. Another substantial portion of the Ustasha Treasury
accompanied Pavelic into exile in Austria in May 1945 where it was hidden.

In late May 1945 Ustasha Regime agents were found at the British-occupied
Austro-Swiss border with gold, currency and other assets valued at 350 million
Swiss francs. Over 200 million Swiss francs value of this particular hoard were
eventually transferred to the Croatian Confraternity at Saint Jerome, Mandic and
Draganovic and then to the Vatican City financial system and elsewhere for
conversion. One portion of the horde contained in two chests of gold was
personally brought from Austria by Draganovic for the use of the Croatian
Confraternity in late 1945. The larger portion of the Ustasha Treasury consisting
of a ten truck convoy was commanded by Ustasha Colonel Ivan Babic and
trucked from Northern Italy to the Croatian Confraternity in 1946 by Babic and
Ustasha confederates wearing British uniforms.

In 1943 Ustasha Lt. Colonel Ivan Babic, a veteran of the Ustasha armed forces in
the Soviet Union was dispatched to Italy by Pavelic to make contact with the
Allies about Croatia defecting from the Axis. While Churchill favored an
invasion of east central Europe via Croatia, Roosevelt and Stalin vetoed the plan
at the December 1943 Tehran Conference. When it became apparent the Axis
powers would fall, Babic and Draganovic were tasked with conceiving plans
whereby the Ustasha Treasury could be saved from the advance of the Red
Army. Draganovic and Babic devised a plan in which Ustasha assets would
ostensibly become assets of the Roman Catholic Church with the active
cooperation of OFM. The Ustasha Treasury therefore would not only be saved
from the Communists but from seizure by the Allies as Axis loot.

In 1946 Babic carried out the final leg of the plan when he and Ustasha members
dressed in British uniforms, accompanied by a few men clad as priests escorted
the remainder of the Ustasha Treasury in a 10 truck British flagged convoy
through Northern Italy to the San Girolamo Pontifical College in Rome where it
was received by Mandic, Draganovic and the Confraternity of San Girolamo on
behalf of OFM and certified as property of a Roman Catholic Church entity and

Page | 6
thus eligible for deposit at the Vatican where it would be safe from the Allies. At
some point during the convoy’s journey it was joined by Ante Pavelic personally
who was present for the convoy’s arrival in Rome.

The convoy however was not unloaded at San Girolamo but was parked in a safe
area off the nearby Via Tomacelli where Pavelic and the British uniformed
Ustasha disembarked. Then with care, the convoy’s British indicia were
removed and Vatican license plates provided. The convoy was then driven into
St. Peter’s Square and into the Vatican where it was received by representatives
of the Vatican Bank in their official capacity as depository for Church
contributions from around the world. This single transfer contained the greater
remaining part of the Ustasha Treasury. It was estimated in 1946 to be worth an
estimated 200 million Swiss Francs (approximately $50 million) by US Treasury
Agent Emerson Bigelow who contemporaneously reported the incident to the US
government. These funds were place under the control of Mandic who as OFM
Treasurer had the knowledge, access, and ability to utilize the Vatican financial
system, Vatican extraterritorial rights in Rome, the OFM’s internal resources
and various external OFM and Diocesan accounts to convert the treasure into a
useful form that could be dispersed at will to banks in Spain, Latin America, the
United States and elsewhere in evasion of post war Allied currency and
monetary controls in place in Italy and to promote the Ustasha agenda

The events described in the preceding two paragraphs were documented by

former US Army Counter Intelligence Corps (CIC) Special Agent William
Gowen in 1947. Gowen investigated the Ustasha on behalf of the CIC in Rome
which was interested in interdicting the ratline and other human smuggling rings.
As part of his official duties Gowen interviewed Draganovic and Babic who
admitted their roles in the delivery of the Ustasha Treasury to San Girolamo and
the Vatican. Three additional named informants of Gowen also verified the
events related to Gowen by Babic and Draganovic. These were Ferenc Vajta, the
former Hungarian Consul in Vienna 1944-1945 and who served as an informant
for French Intelligence in Innsbruck, Austria in 1946 and was involved in
smuggling Hungarian assets to Rome and Austria; Dr. Miha Krek, former
Deputy Premier of the wartime Royal Yugoslav government in exile who in
1946 was an officer of the British sponsored Central European Federal Club
“Intermarium” in Rome and was sentenced in absentia to 15 years in prison by
the post war Communist government of Yugoslavia, and Monsignor Augustin
Juretic who in 1941-1942 had served as a consultant to the Croatian Catholic
Episcopal Congress with Draganovic and left Croatia in 1942 for exile in
Switzerland and Italy due to political differences with the Ustasha regime and
became an Allied informant.

Page | 7
In Mr. Gowen who still resides in New York City was cross examined during
two depositions by attorneys representing the IOR and OFM in 2005-2006.
These deposition transcripts are available upon request. We have recently
located a direct witness to money laundering of the Ustasha Treasury by
individuals affiliated with the IOR and OFM in post Second World War Italy.
He is in his 90’s and resides in Canada.

Other remnants of the Ustasha treasury arrived in similar fashion 1946-1948,

first to Mandic, Draganovic and the Croatian Confraternity and then dispersed
though either Vatican City, Vatican extraterritorial properties in Italy, or OFM
accounts In late 1945 two boxes containing 45 kilograms of the Austrian gold
horde were entrusted to Draganovic who personally delivered it to Mandic and
the Croatian Confraternity of San Girolamo in Rome to set up operations there.
In 1948 a tranche of 2,400 kilograms of Ustasha Treasury gold was moved from
accounts in Vatican City to Swiss bank accounts. In 1952 the Ustasha leader
Pavelic transferred 5 million Swiss francs from the Ustasha Treasury horde from
Switzerland to Argentina.

Between 1946-1952 Draganovic and Mandic using funds from the Ustasha
treasury helped hundreds of Ustasha criminals avoid justice and flee Allied
jurisdiction. They also assisted the Ustasha organization by providing safe
houses in Rome and dispensing funds worldwide to support the Ustasha exiles
including in the United States and supporting Ustasha interventions in
Yugoslavia. In 1948 Draganovic was accused by the Yugoslav government of
infiltrating 95 Ustasha “spies and terrorists” into Croatia. Mandic was so
intermeshed with the Ustasha exile movement, that the Ustasha government in
exile funded by the Mandic controlled Ustasha Treasury under the leadership of
the Ustasha regime’s former Vice President, Djafer beg Kulenovic, issued a
postage stamp in honor of Mandic in 1951 for use in regions of Herzegovina
under the alleged control of Ustasha partisans. The postage stamp with Mandic’s
portraiture was noted in the New York Times on August 19, 1951 on page 98 in
an article by columnist Kent B. Stiles.

The second phase of OFM involvement began in 1951 with the splitting of the
Ustasha Treasury related activities between Rome, where Draganovic continued
at the Croatian Confraternity, and Chicago where Mandic established a pro
Ustasha cultural and publishing enterprise with money from the Ustasha
Treasury at the OFM controlled Croatian Custody of the Holy Family of
Chicago henceforth Croatian Custody. The Croatian Custody or Commissariat as
it was then known was an administrative dependency of the OFM Minister
General in Rome and Mandic’s relocation there was explicitly approved by the
OFM Minister General. The publishing entity was used to print propaganda
favorable to the Ustasha program and Croatian independence.

Page | 8
Promotion of a Croatian nationalistic agenda at the Croatian Custody of the Holy
Family of Chicago continued after Mandic’s death in 1979 with access to
residual funds from the Ustasha Treasury on through the establishment of
Croatia as an independent state in 1991. The Croatian Custody continued to
support the Croatian nationalist cause through the conflict in former Yugoslavia
by materially supporting the controversial unapproved nationalist shrine of
Medjugorje, located in the Croatian sector of Bosnia, Herceg-Bosna, and
provided support to the shrine’s main promoters - OFM priests like Jozo Zovko,
Tomislav Vlašić, Slavko Barbaric and Svetozar Kraljevic. 1987-2000 the
Croatian Custody maintained an active position at Medjugorje through its own
friar, Fr. Philip Pavic, who served at Medjugorje as confessor and pilgrim
assistant. In 2009, the Congregation for the Doctrine of the Faith (CDF)
condemned Vlašić for disobedience and then left the priesthood.

Other recipients of funds from the Ustasha Treasury, laundered and converted by
through IOR accounts included the Ustasha war criminals: Ante Pavelic, leader
of the Ustasha Regime who went in to exile in Argentina and Spain; Andrija
Artukovic, Ustasha Minister of the Interior, who fled to California; Ante
Bonifacic, former Ustasha official and Leader of the Croatian Government in
Exile, who fled to Chicago; Stepan Hefer, Ustasha Minister of Agriculture, who
fled to Argentina; Ustasha Army Commander and Chief Vjekoslav “Maks”
Luburic who fled to Spain; Ustasha regime Vice President Djafer beg Kulenovic
who went to Lebanon; Jasenovac Concentration Camp officer Lt. Petar “The
Throat Slasher” Brzica who fled to the United States; Dinko Sakic, Jasenovac
Concentration Camp Commander, who fled to Argentina and hundreds of others.

By “IOR Accounts” we mean accounts that exist or existed, associated with, or

at one time benefitted the following individuals and organizations:

Andrija Artukovic
Ante Bonifacic
Ante Pavelic
Order of Friars Minor
Croatian Almanac
Croatian Catholic Messenger Newspaper
Croatian Custody of the Holy Family of Chicago
Croatian Historical Society (of Chicago)
Croatian Liberation Movement
Croatian Publishing House Croatia
Danica Newspaper (of Chicago)
Dinko Sakic

Page | 9
Djafer beg Kulenovic
Fr. Krunoslav Draganovic
Fr. Dominik Mandic, OFM
Franciscan Printery (of Chicago)
Ivan Babić
Mirjana Psenicnik
Monsignor Juraj Madjerec
Pontifical Croatian College of St. Jerome
Srecko Psenicnik
Srecko Rover
Stepan Hefer
The Croatian Confraternity of San Girolamo
The Roman Catholic Diocese of Zagreb
Vilko Pecnikar
Vjekoslav “Maks” Luburic
Vjekoslav Vrančić
World League for Freedom and Democracy
World Anti Communist League
Other private accounts associated with related beneficiaries

In order to expedite matters, we would offer to stipulate that this complaint

could be handled outside the parameters the Vatican City State – European
Union Monetary Agreement and the European Commission Letters of January 5,
2011(no. 9319), December 8, 2011 (no. 1324531) referencing Directive
2005160/EC .

I have already tendered to the AIF significant documentation about the Ustasha
Treasury but we stand ready assist you in any way possible. While this offer is
made semi publicly owing to the AIF’s unfortunate decision not to communicate
to date; we would stipulate that any ongoing communications are subject to the
utmost confidentiality and non disclosure should you choose to accept our offer
to discuss this case.

It is well known that the Ustasha Treasury touched on sensitive issues of the
Cold War and more recently the politics of former Yugoslavia. However, there
is no political reason that the Ustasha Treasury issues cannot be put to rest now
to the benefit of the IOR, the Vatican and my clients.

This offer extended in good faith with the hope that the final page may be turned
in this saga.

Page | 10
Sincerely Yours,

Dr. Jonathan Levy

Legal Representative for Ustasha Treasury Claimants

Copies to:

Ernst von Freyberg

President of the IOR Board of Superintendence

Rolando Marranci
General Director

IOR - Instituto per le Opere di Religione

Cortile Sisto V
00120 Vatican City
Vatican City State

Page | 11